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Scottish Climate Change Bill – Call for Evidence The Scottish Government has committed to introducing a new Scottish Climate Change Bill. Recognising progress in Scotland and the Paris Agreement, this will include an ambitious new target of reducing emissions by more than 50% on a gross basis against 1990 levels by 2020. In early 2017 the Government plans to publish a new Climate Change Plan and a new Energy Strategy, which together will set out their low-carbon infrastructure priorities. The Committee on Climate Change has been asked by the Scottish Government to provide advice on how the new Bill may look and is seeking evidence to help with that task. Scotland’s current Climate Change Act sets a long-term target to reduce emissions of greenhouse gases by at least 80% in 2050 relative to 1990, with an interim target to reduce emissions by 42% in 2020.[1] Secondary legislation has also set a series of annual emission reduction targets for 2010 to 2032. Since the Act was passed, the Scottish Government has failed to meet annual targets for 2010 to 2013, but met the 2014 target by a wide margin with reductions of 45.8% since 1990 – outperforming the level of the 2020 interim target.[2] The measure of Scottish emissions under the existing Act has been subject to considerable variability over this period, masking underlying progress in reducing emissions. This has been due to revisions to the Scottish greenhouse gas inventory and changes in the EU Emissions Trading System (EU ETS) that affect the Scottish share of emissions in some years, together with variations in annual temperatures. The changes in the emissions inventory reflect improvements in scientific understanding which led to changes in the methodology for estimating emissions. Such improvements are welcome but they have made the existing annual targets, which are set on an absolute basis, more difficult to achieve. The fact that targets in 2010 to 2013 have been missed is largely due to these revisions. The deadline for responses is 12 noon on 1 February 2017. For information about how to submit your response to this call for evidence, see: https://www.theccc.org.uk/2016/12/14/call-for-evidence-scottish-climate-change-bill/ QUESTION PROFORMA QUESTIONS a. Appropriate level of future emissions (“targets”) A new Scottish Climate Change Act would likely be passed in 2019 and so there will not be much time for new policies to affect progress towards a 2020 target. There is scope for the new Act to include further interim targets between 2020 and 2050 (e.g. for 2030 and 2040). In previous work for Scotland1 we have developed a “High ambition” scenario for Scotland, through which it would be possible for Scotland to achieve a 47% reduction by 2020, on a net basis, outperforming the current 42% target. On a gross basis our High Ambition scenario identifies a possible reduction of 57% in 2020 relative to 1990 emission levels (from emissions in 2014 that were 39.5% below 1990). This includes abatement from all sectors of the economy, with the largest abatement from the continuing decarbonisation of the power sector and increased abatement in transport. The current 2050 target in Scotland, for a reduction of at least 80%, is based on a global path that keeps central (i.e. 50% likelihood) estimates of global temperature rise close to 2°C. The Paris Agreement contains a set of new long-term aims to limit warming, which are more ambitious that previous UN agreements. The Agreement aims to keep the global temperature rise to well below 2°C, pursuing efforts to limit it to 1.5°C. To achieve this, the Agreement aims to balance sources and sinks of greenhouse gases in the second half of the century (i.e. net zero global emissions by 2050-2100). The CCC published a report on the implications for UK climate ambition on the 13th October.2 This concluded that it is not appropriate to set new UK-wide emissions targets now, but agreed with the intention to set a new UK target in future that reflects the global aim of reaching net zero emissions. To be credible, such a target needs to be evidence-based, accompanied by strong policies to deliver existing nearer-term targets and a strategy to develop greenhouse gas removals. The five-yearly cycle of pledges and reviews created by the Paris Agreement provides regular opportunities to consider increasing ambition. The Scottish context differs from that of the UK, both in terms of the existing legislation and in terms of the policy landscape. The different target mechanisms within the 2009 Scottish Act have proven to be more sensitive to inventory revisions, as set out above. Scottish Ministers have made statements regarding their wish to remain at the forefront of global ambition,3 and have committed to a new Bill in response to the Paris Agreement. The Climate Change (Scotland) Act 2009 allows for annual targets (i.e. those currently set for each year to 2032) and the interim target (for 2020) to be amended, within certain limits, via secondary legislation. By contrast, the long-term target for an emissions reduction of at least 80% by 2050 cannot be amended, and no further long-term targets can be added. 1 https://www.theccc.org.uk/publication/scottish-emissions-targets-2028-2032-the-high-ambition-pathway-towardsa-low-carbon-economy/ 2 https://www.theccc.org.uk/publication/uk-action-following-paris/ 3 For example, http://news.gov.scot/speeches-and-briefings/first-minister-address-to-seanad Question 1: To what extent is there scope to increase emission reductions now to meet a more ambitious 2020 target? (Please provide evidence where relevant.) ANSWER: Question 2: To what extent do you support further interim targets between 2020 and 2050 (e.g. for 2030 and 2040)? ANSWER: Question 3: What are the opportunities to reduce emissions to 2050 that go beyond our High Ambition scenario, including opportunities for greenhouse gas removal? (Please provide evidence where relevant.) ANSWER: Question 4: Should the 2050 target be more ambitious than the existing level of ‘at least 80%’? ANSWER: Question 5: Should there be a target for net-zero emissions for Scotland, and if so for when and on what basis? ANSWER: Question 6: If it is not currently appropriate to set a target for net-zero and/or to adopt a more ambitious 2050 target, should provision be made within the new Bill to do so at a later date? ANSWER: b. Duration and form of future carbon targets (one year or multi-year, absolute or percentage) Scottish targets for 2020 and 2050 are currently set as percentage reductions from a 1990 baseline. Annual targets have been set on an absolute (MtCO2e) basis. Annual targets allow for continued assessment of progress and provide greater certainty as to the magnitude of emission reductions that need to be made at any given time. However the ability to meet them can be affected by annual fluctuations in emissions caused by weather or unforeseen factors, while the delay in greenhouse gas inventory data for Scotland means that progress against targets is assessed two years after the target year. Multi-year targets, such as five-year budgets under the UK-wide Climate Change Act, provide greater smoothing of these annual fluctuations, while allowing for monitoring of progress towards longer-term emission reduction targets. Targets on an absolute basis allow for assessment towards total cumulative emissions; however, revisions to the greenhouse gas inventory can make them harder or easier to meet without reflecting actual progress in reducing emissions. This can be more pronounced in Scotland, which as compared with the UK as a whole has a much higher share of emissions from agriculture and land use, in which most revisions occur. Percentage reductions would be less affected by these revisions, but targets on a percentage basis are less strongly linked to the best scientific estimates of the absolute level of emissions, which are the fundamental driver of climate change. When the current 2009 Act was set annual absolute targets and interim percentage targets aligned. However, subsequent revisions to the greenhouse gas inventory have ‘shifted’ the baseline and led to these targets diverging from each other, potentially creating confusion and a loss of transparency. Question 7: Should Scottish targets be set on an annual basis or covering multiple years? If on an annual basis, what can be done to minimise the impact of confounding short-term factors (e.g. weather) on meeting them? ANSWER: Question 8: Should targets be set on percentage or absolute terms? ANSWER: Question 9: What else can be done to make targets resilient to future revisions to the emissions inventory? ANSWER: c. Future accounting framework The Scottish Government has committed to moving to a gross emissions accounting framework (i.e. actual emission reductions from all sectors of the economy will count towards the targets), as opposed to the net basis used in the 2009 Act.1 A move to a gross framework aims to increase transparency around progress to targets in Scotland. A change to gross accounting framework raises issues of; Whether there remains a role for credit purchase in such an accounting framework. The existing Act allows for credit purchase as a means to meet targets, although it also places further targets for “domestic effort” alone. To date, the Scottish Government has not purchased any such credits. Were it to do so, these would need to be procured through a programme that meets a required standard. How the role of emissions trading schemes (such as the EU ETS) should be reflected in such an accounting framework Depending on the future relationship with the European Union, participation in the EU Emissions Trading System (EU ETS) may or may not continue. Question 10: What is the role for credit purchase to supplement action to meet gross targets? ANSWER: Question 11: How should the role of the EU ETS, or other trading schemes, be reflected in the emissions accounting framework used for reporting progress to targets? ANSWER: Question 12: Are there any competitiveness implications for current traded sector business (e.g. industry) to moving to gross targets in Scotland, and if so how could they be minimised? ANSWER: d. Criteria for setting future targets The current Climate Change Act includes target setting criteria which must be taken into account prior to targets being legislated. These are: a. Scientific knowledge about climate change b. Technology relevant to climate change c. Economic circumstances, in particular the likely impact of targets on – - The Scottish economy - The competitiveness of particular sectors of the Scottish economy - Small and medium-sized enterprises - Jobs and employment opportunities d. Fiscal circumstances, in particular the likely impact of targets on taxation, public spending and public borrowing e. Social circumstances, in particular the likely impact of targets on those living in poorer or deprived communities f. The likely impact of targets on those living in remote rural and island communities g. Energy policy in particular the likely impact of the target on energy supplies, the renewable energy sector and the carbon and energy intensity of the Scottish economy h. Environmental considerations and, in particular, the likely impact of the targets on biodiversity i. European and international law and policy relating to climate change Question 13: Are the current target setting criteria listed in the Act still appropriate? Are any missing? ANSWER: